Back to Articles List > NIH Salary Cap Clarification (2012-02-09)

In summary, the guiding document for the salary cap level will be your NOGA for F12, and more specifically, the issue date for that NOGA.  The information outlined below and this attached matrix is intended as general guidance.  For more specific assistance, please contact your Sponsored Program Specialist in the Office of Sponsored Programs (OSP).
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• For NIH FY12 awards with a NOGA issue date on or before 12/22/11, the salary cap is Executive Level I ($199,700 for a 12-month appointment and $149,775 for a 9-month appointment) for the remainder of the current budget period for both competing and non-competing awards. 
• For NIH FY12 awards with a NOGA issue on or after 12/23/11, the Executive Level II ($179,700 for a 12-month appointment and $134,775 for a 9-month appointment) salary cap applies for both competing and non-competing awards.

   1.)      For Competing awards:

• If a detailed budget was submitted with the proposal, then the awarding Institute will adjust the award prior to issuing the NOGA to reflect the Executive Level II salary cap and the reduction in associated F&A costs.  Future years will also be adjusted.
• If a modular budget was submitted with the proposal, then it will be up to Vanderbilt to ensure that no funds are spent on salaries above the Executive Level II salary cap.  No reduction in the total award will occur, therefore, re-budgeting will be required.

 2.)      For Non-competing awards:

• These awards will not be adjusted by the Institute.  If otherwise unrestricted, these awards maybe re-budgeted.
• NIH awards from previous fiscal years are NOT affected by NOT-OD-12-035 and therefore, carry forward funds can be spent on salaries using the Executive Level I cap.

·         For competing applications that include detailed budgets, please continue to note in the budget usjtification an explanation that indicates that actual institutional base salary exceeds the current salary limitation.

• The salary cap level does NOT apply to payments made to consultants under an NIH award although, as with all costs, those payments must meet the test of reasonableness and be consistent with institutional policy.
• The salary cap provisions DO apply to subawards/subcontracts for substantive work under an NIH award.

The OSP, OCGA, and Department of Finance are developing an implementation plan for internal controls to track and monitor affected awards.  We will do our best to make this process as simple as possible for the research community.